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Read H-1B LCA Disclosure Data Without Treating It as Headcount

Conceptual illustration for "Read H-1B LCA Disclosure Data Without Treating It as Headcount"

The Labor Department publishes labor condition applications by employer, job, worksite and wage. Use them to ask a hiring question, and keep layoff claims for other evidence.

What an LCA records

Before an employer files an H-1B petition with U.S. Citizenship and Immigration Services, it submits a labor condition application to the Department of Labor, attesting to the program's requirements on wages and working conditions. DOL reviews it within seven working days for completeness and obvious errors. The same form, ETA-9035, also covers H-1B1 and E-3 workers.

The application states a job title and occupation code, a period of intended employment, how many worker positions it requests and how those positions split between new employment, continued employment, a change of employer and other categories. It also lists wages and places of employment.

Each row, then, is a statement of what an employer asked DOL to certify. A certified LCA doesn't show that a petition was filed, that USCIS approved one or that anyone started work. That limit shapes every sentence you can write from the file.

How the disclosure files work

OFLC posts the files on its Performance Data page, organized by federal fiscal year (October 1 through September 30). OFLC says each data set is cumulative for the fiscal year. The FY2026 third-quarter file, for example, covers determinations issued from October 1, 2025 through June 30, 2026; an application lands in a file according to the date OFLC issued its determination.

Two details in the current record layout change how you count. The main file's worksite and wage columns describe the first worksite only, and additional worksites sit in a separate worksites file with its own layout. And PW_WAGE_LEVEL is filled only when the employer determined the prevailing wage itself from the OES survey; otherwise it reads N/A. OFLC also notes that layouts changed substantially from FY2020, so read the layout for every file you use.

FieldWhat it recordsWhat it can't tell you
CASE_STATUSCertified, Certified-Withdrawn, Denied or WithdrawnWhether a petition was filed or approved
RECEIVED_DATE, DECISION_DATEWhen OFLC received the application and issued its last determinationWhen, or whether, a worker started
TOTAL_WORKER_POSITIONSWorkers the employer requested on the applicationHow many positions were filled
NEW_EMPLOYMENT, CONTINUED_EMPLOYMENT, CHANGE_EMPLOYER and related columnsHow requested workers split by the basis for the petitionWhich of those workers were actually hired or kept
JOB_TITLE, SOC_CODE, SOC_TITLEThe job title and its occupational classificationThe team or product line
WORKSITE_CITY, WORKSITE_STATEThe first worksite on the applicationOther worksites, which are in the separate worksites file
WAGE_RATE_OF_PAY_FROM / _TO, PW_WAGE_LEVELOffered wage range at the first worksite; OES wage level when the employer used itTotal compensation, or the wage level where it reads N/A
EMPLOYER_NAME, TRADE_NAME_DBA, EMPLOYER_FEINThe filing entityParent-company relationships

Field names and definitions from OFLC's FY2026 Q3 LCA record layout. Check the layout published with each file.

Compare matched windows for one employer

Because each file is cumulative, the third-quarter files for two consecutive fiscal years cover the same October-to-June window a year apart. That gives you a fair comparison without stitching quarters together.

  1. Download both files and their record layouts.
  2. Filter to one employer. Check legal-name variants, trade names and the FEIN column, since related entities can file separately.
  3. Keep H-1B rows (VISA_CLASS) and count Certified and Certified-Withdrawn separately.
  4. Sum TOTAL_WORKER_POSITIONS and, separately, NEW_EMPLOYMENT, by occupation code. If your question is about place, use the worksites file.
  5. Measure the same change across the whole file. Policy moves every employer at once: Proclamation 10973 of September 19, 2025 restricted entry for new H-1B workers unless their petitions came with a $100,000 payment, subject to exceptions, for 12 months absent extension. Check its current legal status before you cite it. An employer stands out only if it moved well beyond the file-wide change.
  6. Write only what the counts support.

"Certified new-employment positions for software developers at this employer fell between matched October-to-June windows, per OFLC disclosure files" is a sourced sentence. "The company is preparing layoffs" is a guess.

Pair the file with sources that measure other steps

An LCA, a petition decision and a layoff notice record different events. Use each for what it measures, and look for the company's own account before you connect them.

SourceWhat it recordsTiming and limits
LCA disclosure file (DOL OFLC)Applications and DOL determinationsCumulative fiscal-year files on the Performance Data page
USCIS H-1B Employer Data HubUSCIS's first decisions on petitions for initial and continuing employment, by employerCovers FY2009 onward; employers are identified by the last four digits of the tax ID, so similar names can be hard to separate
WARN noticeA plant closing or mass layoff by an employer with 100 or more employees, excluding part-time workersServed at least 60 days before the closing or layoff, to workers or their representatives and to state and local officials
Company filings and statementsThe company's own accountWhen the company chooses or is required to disclose

Four records, four different events. A change in one is a question for the others.

Keep the causal claim for other evidence

Never write that a company is cutting jobs because its LCA counts fell. Report the change, measure it against the whole file, then ask the company and check WARN notices and its own filings.

Following a tech field

The same discipline applies to the job postings guide and to earnings calls: each source does the job it can support.

A Niche briefing follows coverage in a field you describe and keeps the supporting sources attached. When a story about hiring or layoffs lands in yours, these files are a manual check you can run on the employer, and the matched-window method keeps the claim the size the data allows.

Frequently asked questions

What is H-1B LCA disclosure data?

It's the Department of Labor's public file of labor condition applications (Form ETA-9035) and OFLC's determinations on them. Each row includes the employer, job title, occupation code, requested positions and their basis, the first worksite and the offered wage.

Where do I download it, and how often is it updated?

From OFLC's Performance Data page, organized by federal fiscal year (October 1 through September 30). Files are labeled by quarter, and OFLC says each data set is cumulative for the fiscal year. Each comes with a record layout explaining the columns.

Does a drop in a company's LCA filings mean layoffs are coming?

Not on its own. An LCA is neither a hire nor a petition approval, and filings shift for many reasons, including policy changes that affect every employer. A drop is a question to check against WARN notices, company filings and the company itself.

How is LCA data different from the USCIS H-1B Employer Data Hub?

LCA data records applications and DOL determinations before a petition. The USCIS Employer Data Hub reports USCIS's first decisions on petitions for initial and continuing employment. They measure different steps.

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